2026 marks a watershed year for Food Contact Material (FCM) compliance in the European Union. The new plastics regulation is now in force, and the requirements on Non-Intentionally Added Substances (NIAS) and on the purity of starting substances have become legally binding. Since 16 September 2026, plastic articles produced under the old rules can no longer be placed on the EU market for the first time. RASFF data point in the same direction.
The EU Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) has applied in full since 12 August 2026. All four categories of export packaging — food, pharmaceutical, medical device and tobacco — fall within its scope, but each is primarily governed by a different piece of legislation, and each has a different set of exemptions.
Between July and September 2026, new EU regulations significantly reshaped compliance for food contact materials (FCM). Key changes include a full ban on bisphenol A in single-use FCM, PPWR restrictions limiting PFAS in food packaging, updated purity rules for plastic FCM, and formal PET bottle recycled-content calculation guidelines including chemical recycling. Exporters must now back every shipment with updated Declarations of Conformity, mandatory BPA test reports (1 µg/kg detection limit), and documented PFAS screenings. Furthermore, recent RASFF data highlights bisphenol S, mineral oil, formaldehyde, and primary aromatic amine migrations as top compliance risks requiring routine testing.
CIRS Group has compiled and summarized the latest global cosmetics regulatory developments in August 2026.
The European Commission has published Regulation (EU) 2026/1423, adding chlorpyrifos to Part A of Annex I of the EU POPs Regulation (limit: 0.01 mg/kg), and has adopted a draft amendment listing LC-PFCAs (C9–C21), their salts and related compounds (limits: 0.025 mg/kg and 0.26 mg/kg respectively), which will apply from 16 December 2026. Companies exporting to the EU should monitor these developments and prepare for compliance in advance.
The European Commission’s updated REACH Restrictions Roadmap outlines the EU’s accelerating efforts to phase out high-risk chemicals via grouped control and rolling reviews. Covering 15 adopted measures, 9 pending decisions, and dozens of prospective restrictions—including PFAS, CMRs, and heavy metals—it signals a crucial shift toward substitution-first strategies for industry compliance.
Recently, the European Union's Rapid Alert System for non-food consumer products (Safety Gate) has reported multiple cases of non-compliance with the EU RoHS Directive, mainly involving restriction requirements for lead (Pb), cadmium (Cd), bis(2-ethylhexyl) phthalate (DEHP) and short-chain chlorinated paraffins (SCCPs). The non-compliant products listed below have been notified and subject to enforcement measures. CIRS Testing advises relevant manufacturers, exporters and supply-chain stakeholders to strengthen quality control in order to mitigate trade risks.
Under the EU Packaging and Packaging Waste Regulation (PPWR), "Producer" is an Extended Producer Responsibility (EPR) role assigned to manufacturers, importers, or distributors who first place packaging on a Member State’s market. Producers face strict registration, fee, and reporting obligations. Non-EU sellers must appoint an Authorized Representative, while platforms like Amazon verify compliance.
On August 27, 2026, the European Chemicals Agency (ECHA) announced the addition of 10 new substance testing proposals and invited public comments by October 12.
Below are the most critical points that chemical enterprises should prioritize.
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